Meeting with NAVSEA and OSHA

July 29, 2010

Department of Labor

Washington, DC

On Thursday July 29, 2010, a meeting was held with representatives of
the Department of Labor’s Occupational Safety and Health
Administration (OSHA) and the U.S. Navy’s Naval Sea Systems Command
(NAVSEA) at the Department of Labor.  The purpose of the meeting was to
discuss the control of hazardous energy at landside shipyard facilities
and on vessels and vessel sections that will be regulated by Subpart F
(29 CFR 1915.80 et seq., “General Working Conditions in Shipyard
Employment”) upon its effective date.  That date will be specified
when the final standard is published in the Federal Register, currently
anticipated for the end of 2010.  The meeting was attended by the
following people:

Adams, Stewart (NAVSEA)

Biersner, Robert (DOL/Solicitor’s Office)

Brice, Jim (NAVSEA)

Brinkerhoff, Susan (DOL/Solicitor’s Office)

Colahan, Paul (NAVSEA)

Daddura, Joe (OSHA)

Dougherty, Dorothy (OSHA)

Maddux, Jim (OSHA)

McKenzie, John (NAVSEA)

Taylor, Kim (NAVSEA)

Wallis, David (OSHA)

Watson, Danielle (OSHA)

Watson, Dave (NAVSEA)

The NAVSEA representatives gave OSHA a presentation on the Navy’s
procedures in controlling hazardous energy in complex conditions that
exist at Navy shipyards.  The complexity of the conditions arises from
employees concurrently working on various vessel systems that share
power sources, and from groups of employees working on the same system
at the same time.

The Navy’s system involves several layers of oversight and
coordination, which were described as set forth in Exhibit 1, attached
hereto.  The Navy discussed the path through which documentation of a
work task involving lockout/tagout (LOTO) makes its way in a shipyard,
from the initial Work Control Group, which coordinates all LOTO
applications, to the work force.  NAVSEA also described that individual
employees in the work force ensure their own protection from hazardous
energy by visually accounting for the presence, in their specific work
area, of the package containing the documentation (“Official Work
Package”).  The Official Work Package is under the physical control,
at all times, of a lead employee, and it serves as visual evidence that
a system has been locked out or tagged out and is safe to work on.  If
the lead employee does not have the Official Work Package in his
possession, employees working under him must not begin work.  

After a brief description by OSHA of the pending final rule, OSHA and
NAVSEA discussed a comparison of the Navy system to OSHA’s group LOTO
systems in general industry and in the electric power generation
industry.  OSHA’s regulations require that each employee authorized to
service a system under LOTO take two affirmative steps – one at the
beginning of the work process, and one at the end.  These affirmative
steps serve as the employee’s acknowledge that:  (1) the system he or
she is servicing has been locked out or tagged out; and (2) the system
has been reenergized, and he or she may not continue servicing it.

NAVSEA also offered OSHA examples of regulatory text that the Navy
thought would be helpful as OSHA prepares the final standard for
publication.  That document is attached hereto as Exhibit 2.

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